Eligibility certificate governs central sales tax exemption; assessing authority cannot deny relief for lack of registration.

An exemption notification under section 8(5) of the Central Sales Tax Act operated on satisfaction of the prescribed schedule conditions and production of an eligibility certificate from the Industries Commissioner. Once the competent authority issued that certificate on approval and recommendation of the State Level Committee, the assessing authority could not question its correctness or go behind it. The certificate remained decisive for exemption until revoked or amended by the competent authority. The assessee was therefore entitled to exemption on the inter-State sales covered by the certificate, and absence of registration under section 7(1) did not justify denial of the exemption.

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Issues: Whether the assessee was entitled to exemption from central sales tax on inter-State sales under the State notification on the strength of an eligibility certificate, notwithstanding the absence of registration under section 7(1) of the Central Sales Tax Act, 1956.

Analysis: The exemption notification issued under section 8(5) of the Central Sales Tax Act, 1956 required the dealer to satisfy the conditions stated in the schedule and to produce a certificate from the Industries Commissioner certifying eligibility. The certificate had been issued on approval and recommendation of the State Level Committee. Once such a certificate was issued by the competent authority, the assessing authority could not go behind it or question its correctness. The statutory scheme made the eligibility certificate decisive for the grant of exemption until it was revoked or amended by the competent authority.

Conclusion: The assessee was entitled to exemption from tax on the inter-State sales covered by the eligibility certificate, and the absence of registration under section 7(1) of the Central Sales Tax Act, 1956 did not justify denial of the exemption.

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